ML24113A287
| ML24113A287 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs, Dresden, Peach Bottom, Nine Mile Point, Byron, Braidwood, Limerick, Ginna, Clinton, Quad Cities, FitzPatrick, LaSalle  |
| Issue date: | 04/25/2024 |
| From: | Scott Wall NRC/NRR/DORL/LPL3 |
| To: | Constellation Energy Generation |
| Wall S, NRR/DORL/LPL3 | |
| References | |
| EPID L-2024-LRM-0041 | |
| Download: ML24113A287 (1) | |
Text
April 25, 2024 LICENSEE:
Constellation Energy Generation, LLC FACILITIES: Braidwood Station, Units 1 and 2; Byron Station, Unit Nos. 1 and 2; Calvert Cliffs Nuclear Power Plant, Units 1 and 2; Clinton Power Station, Unit No. 1; Dresden Nuclear Power Station, Units 2 and 3; James A. FitzPatrick Nuclear Power Plant; LaSalle County Station, Units 1 and 2; Limerick Generating Station, Units 1 and 2; Nine Mile Point Nuclear Station, Units 1 and 2; Peach Bottom Atomic Power Station, Units 2 and 3; Quad Cities Nuclear Power Station, Units 1 and 2; and R. E. Ginna Nuclear Power Plant
SUBJECT:
SUMMARY
OF APRIL 9, 2024, PUBLIC MEETING WITH CONSTELLATION ENERGY GENERATION, LLC REGARDING ESCAPE HOODS (EPID L-2024-LRM-0041)
On April 9, 2024, a public meeting was held between the U.S. Nuclear Regulatory Commission (NRC) and representatives of Constellation Energy Generation, LLC (CEG, the licensee). The purpose of this meeting was to discuss the concept of using escape hoods for security personnel in lieu of the licensees current fitted gas masks at Braidwood Station, Units 1 and 2; Byron Station, Unit Nos. 1 and 2; Calvert Cliffs Nuclear Power Plant, Units 1 and 2; Clinton Power Station, Unit No. 1; Dresden Nuclear Power Station, Units 2 and 3; James A. FitzPatrick Nuclear Power Plant; LaSalle County Station, Units 1 and 2; Limerick Generating Station, Units 1 and 2; Nine Mile Point Nuclear Station, Units 1 and 2; Peach Bottom Atomic Power Station, Units 2 and 3; Quad Cities Nuclear Power Station, Units 1 and 2; and R. E. Ginna Nuclear Power Plant (collectively, the CEG facilities). The meeting notice and agenda dated March 12, 2024, are available in the Agencywide Documents Access and Management System (ADAMS) at Accession No. ML24074A061, and CEGs meeting handout is available at ML24089A261. A list of attendees is enclosed.
The licensee presented information regarding a potential change from its current full-face, fitted gas mask to an escape hood-style air purifying respiratory protective device for security personnel at the CEG facilities. During the meeting, the licensee:
provided a high-level comparison between the current fitted mask used by CEG security personnel, the Avon PC50, and the proposed escape hood mask, the Avon NH15; discussed the various regulatory requirements and guidelines pertaining to respiratory protection; provided a detailed description of the Avon NH15 Air Purifying Escape Respirator Mask as background for justification for the potential change, and outlined potential licensing options that would allow the use of the Avon NH15 style mask.
The NRC staff noted that the regulations do not require the use of fitted protective masks and further that regardless of the method CEG may use to implement escape hoods (i.e., Title 10 of the Code of Federal Regulations (10 CFR) 50.54(p)(2), 10 CFR 73.5, or 10 CFR 73.55(r)), CEG should ensure that its security personnels use of escape hoods enables them to perform their assigned duties and responsibilities for the duration of the reasonable assurance of protection time (RAPT). The RAPT is described in SECY-20-0070, Technical Evaluation of the Security Bounding Time Concept for Operating Nuclear Power Plants, dated July 30, 2020 (ML20126G265), and in section 1.2 of Regulatory Guide (RG) 5.76, Physical Protection Programs at Nuclear Power Reactors (SGI), Revision 1, dated November 2020.
During the public comment portion of the meeting, in response to a question received from a member of the public, the NRC staff provided the following feedback:
Reasonable Assurance of Protection Time (RAPT): A public member indicated that if RG 5.76 was revised in 2020 to allow licensees to credit local law enforcement response after 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, and that if mask filters only lasts 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, how did the licensees meet the at all times requirement prior to the revision?
The NRC staff indicated that the RAPT reflects the staffs determination that a licensees current physical protection program meets the general performance objective of 10 CFR 73.55(b)(1) to provide reasonable assurance that activities involving special nuclear material are not inimical to the common defense and security and do not constitute an unreasonable risk to the public health and safety when that program is capable of independently defending against the design basis threat of radiological sabotage for a timeframe of at least 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. The staff indicated that prior to November 2020, the NRC had generally considered 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to be a sufficient period for licensees to demonstrate reasonable assurance of adequate protection, and the November 2020 revision to RG 5.76 simply provided formal clarification of the staffs bases and the Commissions expectation.
The NRC staff appreciated that the licensee held the meeting early in the development process so that staff comments could be considered in any licensing application CEG may elect to submit.
Two members of the public participated in the meeting. No regulatory decisions were made at this meeting. No feedback forms were received.
Please direct any inquiries to me at 301-415-2855, or Scott.Wall@nrc.gov.
Sincerely,
/RA/
Scott P. Wall, Senior Project Manager Plant Licensing Branch III Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. STN 50-456, STN 50-457, STN 50-454, STN 50-455, 50-317, 50-318, 50-461, 50-237, 50-249, 50-333, 50-373, 50-374, 50-352, 50-353, 50-220, 50-410, 50-277, 50-278, 50-254, 50-265, and 50-244
Enclosure:
List of Attendees cc: Listserv
Enclosure LIST OF ATTENDEES APRIL 9, 2024, PUBLIC MEETING WITH CONSTELLATION ENERGY GENERATION, LLC SECURITY FORCE PROTECTIVE GAS MASK Name Organization Scott Wall Nuclear Regulatory Commission (NRC)
Anthony Bowers NRC Jeff Whited NRC Desiree Davis NRC Lou Cubellis NRC Jeremiah Rey NRC David Hostetter NRC Steven Sarver NRC Wellington Tejada NRC Douglas Batche Constellation Energy Generation, LLC (CEG)
John Young CEG Ron Reynolds CEG Michael Kunzwiler CEG Richard Gropp CEG David Gudger CEG Mike Whitlock Nuclear Energy Institute (NEI)
Edwin Lyman Union of Concerned Scientists
ML24113A287 NRC-001 OFFICE NRR/DORL/LPL3/PM NRR/DORL/LPL3/LA NRR/DORL/LPL3/BC NAME SWall SRohrer JWhited DATE 04/22/2024 04/23/2024 04/25/2024 OFFICE NRR/DORL/LPL3/PM NAME SWall DATE 04/25/2024